Personal Injury Complaint - Slip and Fall

SUPERIOR COURT OF THE STATE OF CONNECTICUT

Judicial District of [PLACEHOLDER – JUDICIAL DISTRICT]
Docket No.: [___]

COMPLAINT – PREMISES LIABILITY (SLIP-AND-FALL)

Date: [___]

TABLE OF CONTENTS

1. Parties
2. Jurisdiction and Venue
3. Factual Allegations
4. Count One – Negligence (Premises Liability)
5. Damages
6. Prayer for Relief
7. Demand for Jury Trial (Optional)
8. Statement of Amount in Demand
9. Certification of Service

1. PARTIES

1.01 Plaintiff, [PLAINTIFF NAME] (“Plaintiff”), is an individual resident of the State of [STATE] and, at all relevant times, was lawfully present on the premises described herein.

1.02 Defendant, [DEFENDANT NAME] (“Defendant”), is a [corporation/LLC/partnership/individual] organized and existing under the laws of the State of [STATE] with its principal place of business at [ADDRESS]. Defendant owned, possessed, controlled, and/or maintained the premises located at [PREMISES ADDRESS] (the “Premises”) at all relevant times.

2. JURISDICTION AND VENUE

2.01 Jurisdiction is proper in this Court pursuant to Conn. Gen. Stat. § 51-164s (Superior Court is the sole court of original jurisdiction) and Conn. Gen. Stat. § 52-91 because the amount, legal interest, or property in demand is fifteen thousand dollars ($15,000.00) or more, exclusive of interest and costs.

2.02 Venue is proper in the Judicial District of [JURISDICTION] pursuant to Conn. Gen. Stat. § 51-345 because the cause of action arose in this district and/or the Defendant transacts business and may be found here.

3. FACTUAL ALLEGATIONS

3.01 On [DATE] at approximately [TIME], Plaintiff was an invitee (a business invitee, public invitee, or social invitee under Conn. Gen. Stat. § 52-557a) lawfully on the Premises.

3.02 While traversing [describe specific location, e.g., “the tiled foyer adjacent to the main entrance”], Plaintiff slipped and fell due to [describe hazard—e.g., “an accumulation of water and cleaning solution with no warning signs”] (the “Hazardous Condition”).

3.03 At all relevant times, Defendant, by and through its agents, servants, and/or employees, knew or, in the exercise of reasonable care, should have known of the Hazardous Condition.

3.04 Defendant failed to:

a. Inspect and maintain the Premises in a reasonably safe condition;
 b. Warn Plaintiff of the Hazardous Condition;
 c. Remedy or cordon off the Hazardous Condition within a reasonable time; and
 d. Adopt reasonable safety and cleaning protocols to prevent such hazards.

3.05 As a direct and proximate result of Defendant’s negligence, Plaintiff suffered serious personal injuries and related damages more fully set forth below.

4. COUNT ONE – NEGLIGENCE (PREMISES LIABILITY)

4.01 Plaintiff repeats and realleges ¶¶ 1.01–3.05 as if fully set forth herein.

4.02 Under Connecticut's common-law premises-liability framework, which classifies entrants as invitees, licensees, or trespassers, Defendant — as possessor of the Premises — owed Plaintiff, an invitee, the highest duty of care owed to any entrant: a duty to reasonably inspect the Premises for hazards, to remedy known or reasonably discoverable hazards within a reasonable time, and to warn of hazards that Defendant knew or should have known of and that Plaintiff could not reasonably have been expected to discover.

4.03 Defendant breached said duty by the acts and omissions described in ¶ 3.04.

4.04 Defendant’s breach was the direct and proximate cause of Plaintiff’s injuries and losses.

4.045 Pursuant to Conn. Gen. Stat. § 52-572h(b), any comparative negligence attributable to Plaintiff shall diminish, but not bar, Plaintiff's recovery unless Plaintiff's negligence is found to be greater than the combined negligence of the Defendant(s). If more than one Defendant is found negligent, pursuant to § 52-572h(c)-(d) each such Defendant is liable to Plaintiff only for that Defendant's proportionate share of the recoverable economic and noneconomic damages (several, not joint-and-several, liability), except as otherwise provided by law.

4.05 Plaintiff’s injuries include, but are not limited to:
 a. [Physical injuries – e.g., “left ankle fracture requiring open reduction and internal fixation”];
 b. Pain and suffering, both past and future;
 c. Lost wages and diminution of earning capacity;
 d. Past and future medical expenses;
 e. Loss of enjoyment of life; and
 f. Any and all other damages proven at trial.

5. DAMAGES

5.01 Pursuant to Conn. Gen. Stat. § 52-91, Plaintiff seeks monetary damages in excess of Fifteen Thousand Dollars ($15,000.00), exclusive of interest and costs.

5.02 Plaintiff reserves the right to amend this Complaint to claim additional special damages as they become known.

6. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in Plaintiff’s favor and against Defendant as follows:

A. Compensatory damages in an amount to be determined by the trier of fact;
B. Pre-judgment and post-judgment interest as allowed by law;
C. Costs of suit under Conn. Gen. Stat. § 52-257;
D. Such other and further relief as the Court deems just and proper.

7. DEMAND FOR JURY TRIAL [OPTIONAL]

Pursuant to Conn. Gen. Stat. § 52-215 and Practice Book § 14-10 (Claims for Jury), Plaintiff demands a trial by jury on all issues so triable. A written jury claim must be filed with the clerk within 30 days after the return day or within 10 days after an issue of fact is joined, whichever applies.

8. STATEMENT OF AMOUNT IN DEMAND

In accordance with Conn. Gen. Stat. § 52-91, the amount, legal interest and property in demand is greater than Fifteen Thousand Dollars ($15,000.00), exclusive of interest and costs.

9. CERTIFICATION OF SERVICE

I hereby certify that a copy of the foregoing Complaint was or will be mailed or delivered electronically or non-electronically on [DATE OF SERVICE] to all counsel and pro se parties of record in accordance with P.B. §§ 10-12 and 10-13.

Respectfully submitted,

______________________________
Signature
[ATTORNEY NAME], Esq.
Juris No.: [___]
[LAW FIRM NAME]
[ADDRESS]
Tel: [___]
E-mail: [___]
Attorney for Plaintiff

VERIFICATION (If Required)

I, [PLAINTIFF NAME], being duly sworn, state that I have read the foregoing Complaint and that the allegations therein are true to the best of my knowledge and belief.

______________________________
[PLAINTIFF NAME]

Subscribed and sworn to before me on this ___ day of ________, 20__.

______________________________
Notary Public / Commissioner of the Superior Court
My Commission Expires: [___]